The Financial Crimes Enforcement Network (FinCEN) has adopted an interim final rule that significantly narrows the scope of beneficial ownership information (BOI) filing requirements. The interim final rule (i) removes the requirement for U.S. companies and U.S. persons to report BOI, and (ii) revises the definition of “reporting company”  to mean only those entities that are formed under the law of a foreign country and that have registered to do business in any U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or similar office (formerly known as “foreign reporting companies”).

• If registered in the U.S. before March 21, 2025, foreign reporting companies must file BOI reports by April 20, 2025.
• If registered in the U.S. on or after March 21, 2025, foreign reporting companies will have 30 calendar days to file an initial BOI report after receiving notice that their registration is effective.

Foreign entities that meet the new definition of a “reporting company” will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any such entity for which they are a beneficial owner.

To view the order, click here.

If you have any questions related to the CTA or your potential reporting obligations, please contact your Wiggin and Dana attorney.